The British Disability Discrimination Act (DDA) marks an important turning point in the history of disability civil rights in Great Britain. The DDA was the first legislation in Europe to specifically acknowledge that disabled people suffer from discrimination in a number of fields and public services including employment, education and transportation. However, people across the political spectrum have criticized the DDA.
This note compares the DDA with its United States counterpart, the Americans with Disabilities Act (ADA), which is widely regarded as the most comprehensive and radical legislation of its kind in the world. This note pays particular attention to how the two statutes and their respective, emerging bodies of case law define "disability."
Disabled Meanings: A Comparison of the Definitions of Disability in the British Disability Discrimination Act of 1995 and the Americans with Disabilities Act of 1990,
23 Hastings Int'l & Comp. L. Rev. 149
Available at: https://repository.uchastings.edu/hastings_international_comparative_law_review/vol23/iss1/5